Last Reviewed Date: 09/02/2024

 

This Privacy Policy (“Policy”) describes the information which CULTSHUB Pvt Ltd (“We”, “Us”, “Our”, “Company” “CULTSHUB”) collects from you when you download, access, or use its websites or Mobile Application(“Sites”) for delivery of information, products, offerings, and content via any mobile or internet connected device or otherwise (collectively the “Services”).

CULTSHUB owns and operates several interactive websites, and mobile-connected applications, including their and other online interactive features and services (collectively “services” or “our services”).

This policy covers information collected through the following websites and mobile applications.

  1. CULTSHUB
  2. TorqueXpert
  3. Xvell
  4. CultsByte
  5. OnRush
  6. enteons.com

Applications:

  1. Xvell

 

This Privacy Policy should be read in conjunction with the Terms of Use applicable to the Services you are using.

Please keep in mind that when you provide information to Us on a third-party site or platform (for example, via Our websites or applications like social media login). The information We collect through those third-party sites linked with Our Sites is covered by this Privacy Policy, and the information the third-party site or platform collects is subject to the third-party site or platform’s privacy practices. Privacy choices you have made on the third-party site or platform will not apply to Our use of the information that we have collected directly through Our Sites.

Please also keep in observance that Our Sites and applications may contain links to other sites not owned or controlled by Us and We are not responsible for the privacy practices of those sites. We encourage you to read the privacy policies of other sites that may collect your personal information.

All capitalized terms that have not been specifically defined herein shall have the same meaning as provided under the Terms of Use.

 

User Consent

By using the Services (for example, when you register for an account, communicate with us, on Our Sites or applications or through social media), you agree and provide consent to Our collection, use, and sharing of your personal information as described in this policy. To place the request to delete or download your data – Please apply here. https://www.CULTSHUB.com/gdprform

 

Accessing Sites and  Services through VPN

You should not access or use the Site or  Services using any mechanism or technology that conceals your actual geo-location or provides incorrect details of your location (for example, use a virtual private network (VPN) to access Services, proxy server).

We will not be responsible or liable for any collection, storage, or processing of your personal information or data if you use any mechanism or technology to access or use the Sites or Services that conceal your actual geo-location.

 

Usage of our Mobile Applications

This policy shall also apply to our mobile applications. You are urged to update to the most current version of mobile applications. If you use an older version of these apps and/or access discontinued services, we may not be responsible or liable for any damages, due to any collection, storage, and processing of your personal information as per the older version of the mobile application.

 

COLLECTION AND USE OF PERSONAL INFORMATION

A. Information you provide to Us

Information Collected at the time of registration

During registration, we ask that you provide basic personal information from you to continue to interact with you and to continue providing you the Services.  The company may collect the following information and data depending on the extent of use of the Sites and/or Services: –

  • First/Last Name
  • Sex,
  • Age,
  • City, State, Address,
  • E-mail id
  • Contact number/Mobile No.
  • DOB
  • Occupation
  • Interests
  • Information you provide to Us voluntarily

If you send Us any personal correspondence, such as emails or letters, or if other users or third parties send Us correspondence about your activities or postings on the Site, we may collect and store such information.

We may collect additional information (for example, your name, e-mail ID, mobile number, location, etc.,) at other times, including but not limited to, when you provide feedback(s), modify your content or email preferences, respond to surveys, provide comments, or communicate with Us.

B. Information is automatically collected while browsing/navigating through the Site

Cookies

The Site uses cookies and other similar technologies that are necessary for its functioning and to provide Services. Some of these cookies are essential for Us to provide you with the Services. For more information about essential cookies

To improve the responsiveness of the Sites for our Users, we may use “cookies”, or similar electronic tools to collect information to assign each visitor a unique, random number as a User Identification (User ID) to understand the User’s interests using the identified computer or device. Unless you voluntarily identify yourself (through registration, for example), we will have no way of knowing who you are, even if we assign a cookie to your computer or device. The only personal information a cookie can contain is information you supply. A cookie cannot read data off your hard drive or device. Our advertisers may also assign their cookies to your browser (if you click on their ads etc.), a process that we do not control. We receive and store certain types of Information whenever you interact with us via Site or Service through your computer/laptop/netbook or mobile/tablet/pad/handheld device etc.

Opting out

If a User opts out using the Ads Settings, the unique DoubleClick cookie ID on the User’s browser is overwritten with the phrase “OPT_OUT”. Because there is no longer a unique cookie ID, the opt-out cookie can’t be associated with a particular browser.

You can opt out of Google Analytics for display advertising and customize Google Display Network ads using the Ads Settings options provided by Google.

If you are interested in opting out from specific interest-based ads, you can opt-out through the Privacy Policy page or opt out by writing to the Grievance Officer.

Log File Information

We may automatically collect limited information from your computer/device when you visit our site, application or service, for example;

  • IP address
  • Location/IP address
  • Device serial number/ID
  • In-app permissions for capturing location, storage, network connection, and Wi-Fi connection
  • Advertiser ID/ iDFA
  • pages you view
  • your computer/device’s name,
  • your operating system,
  • browser type and version,
  • CPU speed,
  • connection speed.
  • SSO ID
  • Reviews and comments provided by you
  • Your preferences while using the Sites
  • Your activities and browsing patterns on the Site
  • Articles and Topics, you have read, followed, shared, and saved
  • People you follow and people following you
  • Response to a survey,
  • any communications with us

Clear GIFs

We may use “clear GIFs” (Web Beacons) to track the online usage patterns of our Users anonymously, without personally identifying the User. We may also use clear GIFs in HTML-based emails sent to our Users to track which emails are opened by recipients. We use this information to inter-alia deliver our web pages to you upon request, to tailor our Sites or Services to the interests of our users, to measure traffic within our Sites to improve the quality, functionality, and interactivity of our Sites and let advertisers know the geographic locations from where our Users come without personally identifying the Users.

C. Inferred Information through usage and log data

We may track certain information about you based on your behavior on the Sites. We use this information for conducting internal research on Our users’ demographics (such as age, and gender), devices, interests, and behavior to better understand, protect, and serve Our users.

We may also collect your Information to track user behavior and preferences for internal analytics and research. We may also use your information:

  • To evaluate your interest in various genres of content, services, and offers;
  • To perform analytics and conduct customer research, to determine your interest, identify content that generates sales, and to analyze traffic patterns.

If you choose to post messages on social media accounts, message boards, chat rooms, or other message areas or leave feedback, we will collect the information you provide to Us. We may retain this information as necessary to resolve disputes, provide customer support and troubleshoot problems, and comply with legal obligations under the applicable laws.

The above information may also be captured by keeping cookies on Our Sites by Our affiliates for the purposes mentioned above.

D. Information we collect from third parties

Information obtained from other Sources

We may receive information about you from other online sources. We may add it to Our account information system and treat it following this Privacy Policy. If you provide information to the platform provider or other partner to whom We provide services, your account information may be passed on to Us. We may obtain updated contact information(s) from third parties to correct Our records and fulfill the Services or to communicate with you or share the information with any third party.

Information obtained from Third-party Sites

If you link, connect, or log in to your Services account with a third-party site, they may send Us information such as your registered e-mail ID and public profile information from the service as stated below;

  • Facebook – Email ID and public profile information which may include name, profile picture, age, gender, etc.
  • Google – Email ID, language preference, and age.
  • LinkedIn – Email ID, public information which may include name, profile picture, current position, etc.

Demographic and other information

We may reference other sources of demographic and other information to provide you with more targeted communications and promotions. We use various third-party analytics service providers, among others, to track the user behavior on Our Site. They are used to support display advertising to help Us gain an understanding of Our users’ Demographics and Interests. The reports are anonymous and cannot be associated with any individual personally identifiable information that you may have shared with Us.

Subscription or Paid service data

When you choose any subscription or paid service, We or Our payment gateway provider may collect your personal information such as address or billing information, including your credit/debit card number and expiration date, etc. The subscriptions or paid Services may be on auto renewal mode unless canceled. If at any point you do not wish to auto-renew your subscription, you may cancel your subscription before the end of the subscription term or contact Us on Our support e-mail.

Transactional/ Billing information

Based on your purchase of a subscription or paid service, our payment gateway partner may collect information, including but not limited to, your credit/debit card details or other bank account details along with your billing address. This information is stored by the payment gateway partner. For instance, the Services will be using third-party payment gateway partners to process and facilitate the payment of your subscription fee to the Services for providing you access to the subscription; such payment gateway partners are not controlled by us. When you visit such payment gateways you do so at your own risk. We encourage you to familiarize yourself with the privacy statements provided by such payment gateways before providing them with information about you or entering into any transactions with them. We do not assume any responsibility or liability for such payment gateways, the content of such payment gateways, and their privacy practices, nor do we endorse them.

We may receive financial or transactional information (e.g., transaction ID, etc.) from third-party vendors in case of payments, for reconciliation and validation of transactions, and also for resolutions of complaints (in case of failed transactions and refunds).

 

PURPOSES FOR COLLECTING, PROCESSING AND DISCLOSING YOUR PERSONAL INFORMATION

We use the information to provide, analyze, administer, enhance, and personalize Our service and marketing efforts, to process your registration, to provide you services, and to communicate with you related to the below-mentioned points. For example, we may use information to:

  • To provide you and administer Our services
  • Enabling registration/Sign-up and maintaining your accounts on our Sites
  • Providing you location location-specific content
  • Analyze and understand Our audience, improve Our service (including Our user interface experiences), recommendation algorithms, and delivery which may require sharing personal information with Our group companies and affiliates or third-party service providers
  • To help advertisers understand Our audience and confirm the value of advertising on Our Site (however, it is usually in the form of aggregated statistics on traffic to various pages within our site) and to provide you with relevant ads
  • To provide you with interest-based content like articles, stories, and news on our site
  • Enable your participation in various webcasts and webinars conducted on the Site
  • Provide you with push notifications on your browser.
  • Communicate with you concerning Our service (for example by email), so that We can send you news about Services, details about new features and content available on the Sites, promotional announcements, and surveys, and to assist you with operational requests such as password reset requests.
  • Notify you about changes in terms of service or privacy policy
  • Allow you to participate in interactive features offered through Our Services
  • Sharing with Our customer support team to resolve your queries/concerns related to your rights or services provided to you.

Information Use by the Company

The Information supplied by you enables Us to improve Our services and provide you with the most user-friendly experience(s). In some cases, e.g. provision of certain service(s) or utility (ies), We may require your contact information as well. All required information is service-dependent and the Company may use the above said user Information to, maintain, protect, and improve the Services and for developing new services.

We may also use your email address or other personally identifiable information to send commercial or marketing messages about our Services and/or such additional updates and features about third parties’ products and services with an option to subscribe / unsubscribe (where feasible). We may, however, use your email address for non-marketing or administrative purposes (such as notifying you of major changes, for customer service purposes, billing, etc.)

Any personally identifiable information provided by you will not be considered sensitive if it is freely available and/or accessible in the public domain like any comments, messages, blogs, or scribbles available on social platforms like Facebook, Twitter etc. Any posted/uploaded/conveyed/communication by users on the public sections of the “Site” becomes published content and is not considered personally identifiable information subject to this Privacy Policy. In case you choose to decline to submit personally identifiable information on the Sites, we may not be able to provide certain services on the Sites to you. We will make reasonable efforts to notify you of the same at the time of opening your account. In any case, we will not be liable and or responsible for the denial of certain services to you for lack of you providing the necessary personal information.

When you register with the Application or Services, we contact you from time to time about updating your personal information to provide you with features that we believe may benefit/interest you.

Information sharing with legal authorities, affiliates

Company may share your information with any third parties without obtaining the prior consent of User in the following limited circumstances:

  • When it is requested or required by law or by any court or governmental agency or authority to disclose, for verification of identity, or the prevention, detection, investigation including cyber incidents, or for prosecution and punishment of offenses. These disclosures are made in good faith and the belief that such disclosure is reasonably necessary for enforcing these Terms or for complying with the applicable laws and regulations.
  • Company may share such information with its affiliates/ group companies and officers and employees of such group companies to process personal information on its behalf. We also ensure that these recipients of such information agree to process such information based on Our instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures.

 

Disclosure to Third parties

Service Providers

The Application may include links to other Sites or applications (e.g., links to payment gateways for payment of subscription fees). Such Sites or applications are governed by their respective privacy policies, which are beyond Our control. Once you leave Our servers (you can tell where you are by checking the URL in the location bar on your browser), the use of any information you provide is governed by the privacy policy of the operator of the application or site you are visiting. That policy may differ from Ours. If you can’t find the privacy policy of any of these sites via a link from the Site homepage, you should contact the application/Site owners directly for more information.

Advertisers

When we present Information to our advertisers — to help them understand our audience and confirm the value of advertising on our Sites — it is usually in the form of aggregated statistics on traffic to various pages/content within our Sites. We use third-party advertising companies to serve ads when you visit our Sites. These companies may use Information (excluding your name, address, email address or telephone number, or other personally identifiable information) about your visits to this and other Sites or applications, to provide advertisements about goods and services of interest to you. We do not provide any personally identifiable information to third-party advertisers/ad-servers without your consent.

Merger

In the event the Company is merged with or acquired by another company or in case of reorganization or restructuring of the business, we and Our affiliates may share your personal information, wholly or in part, with another business entity.

Business transfers

We provide personal information to Our affiliates and other trusted businesses or persons to process it for us, based on Our instructions and in compliance with Our Privacy Policy and any other appropriate confidentiality and security measures. This information may be stored by them.

Third-party surveys and promotional Activities conducted on the Site

Surveys, and promotional activities, might be conducted on our Site by associated third-party vendors directly. Your personal information such as name, email, phone number, IP address, country code, etc., may be captured by the vendor, in case you provide the details for participation in the Survey or promotional activity. Please note that personal information may be shared between us and vendors for processing and deriving insights from the survey results, and promotional activity.

 

LINKS TO THIRD PARTY SITES / AD-SERVERS

Our Sites may include links to third-party Sites, applications, and ad servers. The collection of your information including but not limited to PII by such Sites, applications, and/or ad servers are governed by their respective privacy policies, which are beyond our control and We are not responsible for the privacy practices of those sites. We encourage you to read the privacy policies of such third-party sites before sharing your information.

You may share your Information regarding your activities on Sites with third-party social Sites to populate your social wall that is visible to other people.

 

DATA RETENTION AND ERASURE

How long do we store and use your information?

We retain the information which We have collected no longer than is necessary. This is determined on a case-by-case basis. Normally, we will retain the information as long as you maintain an account with Us and till the time you continue to access and use Our Services. We will delete your information as soon as reasonably possible, based on your account activity and by applicable law(s), whenever you request Us to do so. However, we may archive and/or retain some information for legal purposes.

When you use the Services or Sites (or any of its sub-sites), we make good faith efforts to provide you, as and when requested by you, with access to your personal information and shall further ensure that any personal information or sensitive personal data or information found to be inaccurate or deficient shall be corrected or amended as feasible, subject to any requirement for such personal information or sensitive personal data or information to be retained by law or for legitimate business purposes. We ask individual users to identify themselves and the information requested to be accessed, corrected, or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required. In any case, where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort. Because of the way we maintain certain services and/or due to requirements under applicable laws for retaining or preserving information, after you delete your information, such information and/or residual copies may take a period before they are deleted from our active servers and may remain in our backup systems.

Data Erasure

We retain your personal information as long as necessary for Us to provide services to you or you ask Us to not retain your data. If you no longer want Us to use your information then you can request that We erase your personal information and close your Services account as soon as reasonably possible, based on your account activity and by applicable law(s).

We may retain some of your personal information as necessary for Our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if We suspend certain service accounts for fraud or safety reasons, we may retain certain information from that account to prevent that user from opening a new account in the future.

We may retain and use your personal information to the extent necessary to comply with Our legal obligations. For example, we may keep some of your information for tax, legal reporting, and auditing obligations.

Information you have shared with others (e.g., Reviews, forum postings) may continue to be publicly visible on the Sites, even after your account is canceled. However, the attribution of such information to you will be removed. Additionally, some copies of your information (e.g., log records) may remain in Our database but are disassociated from personal identifiers.

Since We maintain copies of personal information to protect from accidental or malicious loss and destruction, residual copies may take a period before they are deleted from Our active servers and may remain in Our backup systems.

You can request for deletion of your information by writing to our designated Grievance Officers, in writing or through email signed with the electronic signature. The list of respective grievance officers is provided in the Terms of Use.

Please note that if you have multiple accounts with Us, then you will have to raise separate requests for each of the accounts, along with the associated email IDs or phone numbers.

Further, we may retain and use Your personal information to the extent necessary to comply with Our legal obligations. For example, we may keep some of Your information for tax, legal reporting, and auditing obligations.

 

CHILDREN’S PRIVACY

Our Service is not intentionally designed for or directed at persons less than 18 years of age. The company does not knowingly permit any person who is under 18 years of age to register with the services or to provide any other personally identifying information. If the Company becomes aware or gets notified that any personally identifiable information of persons less than 18 years of age has been collected on the Sites without verified parental consent, then the Company will take the appropriate steps to delete any such information.

However, we consider it the responsibility of parents to monitor their children’s use of Our services. Nevertheless, it is Our policy not to collect and process any personal information from children below 18 years of age or offer to send any promotional materials to persons in that category. The company does not seek or intend to seek or receive any personal information from children. Should a parent or guardian have reasons to believe that a minor has provided the Company with personal information without their prior consent, please contact the Grievance Officer to ensure that the personal information is removed from the Company Services/Sites.

 

SECURITY MEASURES

We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure, or destruction of data. These include internal reviews of Our data collection, storage, and processing practices, and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where we store personal data. All information gathered is securely stored within the Company controlled database. The database is stored on servers secured behind a firewall on the cloud; access to the servers is password-protected and is strictly limited. However, as effective as Our security measures are, no security system is impenetrable. If you know or have reason to believe that your account credentials have been lost, stolen, altered, or otherwise compromised, or in case of any actual or suspected unauthorized use of your account, please contact Us by reaching out to Our Grievance officer.

 

UPDATES & CHANGES

We may alter Our Privacy Policy from time to time to incorporate necessary changes in technology, applicable law, or any other variant. We reserve the right to amend the terms of this Policy from time to time. Any changes We make will be effective immediately and we may notify the Users by posting the new policy on the Site. Your use of the Sites or Services after such notice shall be deemed as acceptance of such changes. We may also make reasonable efforts to inform you via electronic mail. In any case, you are advised to review the Privacy Policy periodically on the Sites to ensure that you are aware of the latest version

 

GRIEVANCE REDRESSAL

Redressal Mechanism:

Any complaints, abuse, or concerns with regards to the use, processing, deletion, and disclosure of Information provided by you or breach of these terms should immediately be informed to the designated Grievance Officers as mentioned below in writing or through email signed with the electronic signature legal[at]CULTSHUB [dot]com addressing to Mr. Prabanta Priyadarsan- “Grievance Officer”

Any complaints or concerns with regards to content or to report any abuse of laws or breach of these terms may be taken up with the designated grievance redressal officer as mentioned below by sending an email to or via post to

Grievance Redressal Officer

Mr. Prabanta Priyadarsan

Grievance Officer
CULTSHUB Pvt Ltd

1st Floor, 14/129, 1st B Cross
8th Main, BTM 1st Stage
Bengaluru, Karnataka
Bharat (India) – 560029

We request you to please provide the following information in your complaint/Grievance: –

Identification of the information provided by you;

  • Clear statement as to whether the information is personal information or sensitive personal information;
  • our address, telephone number, or e-mail address;
  • A statement that you have a good-faith belief that the information has been processed incorrectly or disclosed without authorization, as the case may be;
  • A statement, under penalty of perjury, that the information in the notice is accurate, and that the information being complained about belongs to you;
  • You may also contact us in case you have any questions/suggestions about the Policy using the contact information mentioned above.
  • The Company may reach out to you to confirm or discuss certain details about your complaint and issues raised.
  • The Company shall not be responsible for any communication, if addressed, to any non-designated person in this regard.